On August 29, 2011, the Department of Labor’s Wage and Hour Division (WHD) issued a final rule to implement President Obama’s Executive Order 13495, Nondisplacement of Qualified Workers Under Service Contracts. The Executive Order requires federal contractors and subcontractors that are successors to certain government contracts to offer employment on a “first right of refusal” to employees (not including managerial or supervisory employees) employed under the predecessor contract, whose employment would be otherwise terminated at the end of the predecessor contract.